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were due to be submitted to the Court), Mr. Kauffman met with Mr.
Gazi and his son in Baltimore, after driving from Florida for
that purpose. At this meeting, which lasted for several hours,
Mr. Kauffman reviewed the settlement offer in the Gazis’ case
with Mr. Gazi and his son for computational errors or omitted
adjustments. Mr. Kauffman then explained to Mr. Gazi and his son
that he would contact Ms. Miller and request further review of
certain items. He gave Mr. Gazi an “approximate number” of the
“fairly large” tax liability that would result from the
settlement agreement and reiterated that petitioners could pursue
previously discussed options in seeking an offer in compromise or
uncollectible status. Mr. Kauffman then went out to dinner with
Mr. Gazi and his son.
Mr. Kauffman subsequently spoke with Ms. Miller and
requested several computational adjustments. Certain
computational adjustments were made, as reflected in the
stipulated decision that was filed with the Court on June 30,
2003.
In November 2003, Mr. Gazi received IRS collection notices
for the liabilities reflected in the stipulated decisions. Mr.
Gazi called Mr. Kell to seek his legal assistance. In a letter
to Mr. Kell dated November 18, 2003, Mr. Gazi wrote: “I have
fired Mr. Kauffman.” Mr. Kell declined to take the case, and Mr.
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